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TurkeyChecked 18 August 2026
Depends on your industryWork: HighEnforcement: Active
In one paragraph
Turkey lets personal data leave, but only after you build the paperwork yourself. The regulator has never declared a single country safe, so the approved-destination list is empty. Most companies use a government-published standard contract and must file it within five working days. The regulator is busy: it fined 876 organisations in 2025.
The catch
The general rule is 'paperwork, then you may send it'. That stops being true the moment you touch payments, banking, telecoms networks, public-sector systems or critical infrastructure. Payment and electronic money firms must keep their systems, their backups and their data inside Turkey, and may only use cloud providers the central bank has approved by name.
Does this apply to me?
Yes. A company with no office in Turkey is still caught, and it is caught harder than a local one. Any organisation based outside Turkey that decides why and how Turkish people's data is used must appoint a representative inside Turkey and sign up to the public register of data controllers before it starts processing. That representative has to be a company set up in Turkey or a Turkish citizen. Turkish small businesses can escape the register if they have fewer than 50 staff and a balance sheet under 100 million lira, but there is no such let-off for foreign companies.High confidence
Can the data leave the country?
It depends entirely on your industry, which is why Turkey is rated 'sectoral'. Under the general privacy law data may leave, but only after you put an approved safeguard in place, because the regulator has not yet declared any country safe. In payments and banking the answer flips to no: systems, backups and data have to sit inside Turkey. Public bodies, critical infrastructure, telecoms networks and health records all carry their own extra restrictions on top.High confidence
What do I have to do to send it abroad?
The model is an approved-destination list, and the list is empty. Nobody can rely on their country being blessed, so almost everyone uses one of the safeguards instead. The usual route is signing one of four standard contracts the regulator publishes, then telling the regulator within five working days of signing. Group companies can instead get binding corporate rules approved, and there is a permission route for bespoke undertakings, but that route almost always fails.High confidence
Who enforces this — and are they actually working?
The Personal Data Protection Authority, and it is fully up and running. In 2025 its board met 42 times, took 2,528 decisions, handled 12,512 complaints and fined 876 organisations a combined 352.5 million lira, which is roughly 8 million US dollars. It publishes named breach announcements most weeks. Financial, telecoms and insurance regulators enforce their own rules alongside it, and a new Cybersecurity Directorate has taken over the national cyber incident centre.High confidence
How long must I keep it, and when must I delete it?
Both directions apply, and the ceiling is unusual. Turkey does not give you a fixed number of months to delete by. Instead, once your reason for holding data runs out, you must erase it at your next scheduled clear-out, and any organisation on the public register has to publish a written retention and destruction policy setting those dates. The floor comes from ordinary commercial and tax law, which forces you to keep books and invoices for years.Medium confidence
What happens when something goes wrong?
There are at least three clocks. The privacy one is 72 hours: from the moment you learn that data has been taken unlawfully, you have three days to tell the Personal Data Protection Board, and you must tell the affected people as soon as you reasonably can. If you miss the 72 hours you must still report and explain why you were late. Companies based abroad have to report too, if people in Turkey are affected.High confidence
What's the trap?
Five things bite people. One: most fines are for paperwork, not privacy. Two thirds of the organisations fined in 2025 were punished for the public register, not for mishandling anyone's data. Two: the bespoke permission route for sending data abroad is close to a dead end, with 76 of 89 applications refused in 2025. Three: filing your standard contract invites inspection rather than closing the file. Four: your representative in Turkey must be Turkish. Five: no country is on the safe list, so there is no shortcut.High confidence
What's about to change?
Two dated items and one direction of travel. Retailers running loyalty cards have until 28 February 2027 to build a way of checking that the person at the till really owns the card, after the regulator extended the original deadline in July 2026. Public bodies are working to a July 2026 ruling on what they may publish online. And the government is pushing openly on data sovereignty, with the President chairing a cyber security meeting in May 2026 that treated data as a strategic asset.High confidence
Hardest industry wall
  • Payments Odeme ve Elektronik Para Kuruluslarinin Bilgi Sistemleri ile Odeme Hizmeti Saglayicilarinin Odeme Hizmetleri Alanindaki Veri Paylasim Servislerine Iliskin Teblig
  • Banking Bankalarin Bilgi Sistemleri ve Elektronik Bankacilik Hizmetleri Hakkinda Yonetmelik
  • Government 2019/12 sayili Bilgi ve Iletisim Guvenligi Tedbirleri Genelgesi ve Bilgi ve Iletisim Guvenligi Rehberi
MexicoChecked 18 August 2026
Depends on your industryWork: MediumEnforcement: Waking up
In one paragraph
Mexico's general privacy law does not care where you store data. There is no approved-country list, no standard contract to sign and no permission to ask for. You need the right wording in your privacy notice and, usually, the person's consent. The rules that actually pin data to Mexico live in banking, money-laundering and tax law, not in the privacy law.
The catch
The relaxed headline stops the moment you are a bank, a stockbroker, a crowdfunding platform, an insurer or a phone company. Banks need written permission from the banking regulator before any processing happens abroad. Separately, anti-money-laundering law and tax law require many ordinary businesses to keep their records at a Mexican address for ten and five years. Those rules bind companies that have never read a privacy law.
Does this apply to me?
Probably yes, but Mexico is unusually vague about it. The privacy law says only that it applies across Mexican territory. It does not spell out when it reaches a company based abroad. The old rulebook did say the law caught a foreign company that used equipment or systems located in Mexico, and let that company appoint a local representative instead of opening an office. That old rulebook belonged to a law that was scrapped in March 2025, so its status today is genuinely unclear. There is no revenue or headcount threshold to fall below.Medium confidence
Can the data leave the country?
Under the general privacy law, yes, and with very little paperwork. Mexico has no list of approved countries and no list of banned ones. Sending data to a company abroad is treated exactly like sending it to a company down the road: say so in your privacy notice, get the person's consent unless one of seven exceptions applies, and pass the privacy notice on to whoever receives the data. Handing data to your own supplier who only follows your instructions is not even counted as a transfer. Five sectors override this, and in three of them the override is severe.High confidence
What do I have to do to send it abroad?
Nothing needs approval and no list exists in either direction. The model is simply unrestricted: any destination is allowed. What you need is a privacy notice that names the transfer and carries a clause where the person accepts or refuses it, plus that person's consent unless one of seven legal exceptions covers you. Because there is no list to populate, the government cannot make this stricter by adding a country. It would take a new law or a new regulation.High confidence
Who enforces this — and are they actually working?
Mexico abolished its independent privacy regulator. The National Institute for Transparency, Access to Information and Data Protection was wound up in March 2025 and its staff, files and cases were moved into a government ministry, the Anti-Corruption and Good Government Ministry. So the referee is now part of the government rather than independent of it. The ministry is staffed, but the law says the detailed procedure for complaints, inspections and fines will be set out in a regulation, and that regulation still has not been published. Financial regulators, by contrast, are visibly active and update their rulebooks almost monthly.Medium confidence
How long must I keep it, and when must I delete it?
There is no single retention period. The privacy law says delete data once it is no longer needed, after a blocking period equal to the time limit for suing over the relationship. One hard ceiling is written into the law: information about someone breaking a contract must be erased six years after the default. The floors are longer and come from other laws. Tax records must be kept five years and their supporting documents must be available at your Mexican tax address. Anti-money-laundering records must be kept ten years at an address you register with the Finance Ministry. Phone companies keep call and location records for two years. Where a floor and a ceiling clash, the floor wins, because the privacy law lets you keep data to meet a legal duty.High confidence
What happens when something goes wrong?
There are at least three clocks and they do not agree. Under the general privacy law you must tell the affected people immediately if a breach significantly harms their money or their reputation, and there is no duty to tell the regulator at all. Banks face a much tighter set: tell the banking regulator immediately, tell affected customers within forty-eight hours, file a full report within five working days, and send a remediation plan within fifteen working days of the incident ending. Phone companies must hand requested records to the authorities within twenty-four hours and keep a team available every hour of every day. Mexico has no general cyber-incident reporting law that catches everyone.High confidence
What's the trap?
Five things catch people out. Every private business in Mexico is now legally required to ask customers for their national population ID number. Anti-money-laundering rules force many ordinary businesses to keep ten years of records at a Mexican address, which quietly rules out a pure foreign cloud setup. Mishandling data can put a person in prison, not just cost a company money. Banks must get written permission before any processing happens abroad, and that includes routine cloud hosting. And the rulebook the privacy law keeps pointing at does not exist.High confidence
What's about to change?
The biggest thing coming is a regulation that is already overdue. The privacy law repeatedly says a rulebook will set the deadlines for complaints, inspections and fines, and the government missed its own June 2025 deadline to publish it. When it lands it could change how enforcement works overnight, with no consultation. Health law was changed in January 2026 to put telehealth on a statutory footing, and the biometric national ID is still being rolled out. The dangerous powers are the ones the government already holds rather than any bill in parliament.Medium confidence
Hardest industry wall
  • Payments Disposiciones de carácter general aplicables a las instituciones de tecnología financiera, artículos 85 a 87
  • Finance Ley Federal para la Prevención e Identificación de Operaciones con Recursos de Procedencia Ilícita, artículos 15 y 18
  • All industries Código Fiscal de la Federación, artículos 28 y 30
  • Telecoms Ley en Materia de Telecomunicaciones y Radiodifusión, artículo 183